The Animal Welfare Act makes it clear that multiple surgical procedures included within one protocol must be justified for scientific reasons and preapproved by the IACUC1,2.

We feel that Wycoff has not adequately justified the scientific reasons. His argument about subjecting fewer animals to more pain is not scientific. Wycoff also proposed only “adequate” pain control. The definition of adequate is open to interpretation but may imply that there is room for improvement. One way that Wycoff could convince the IACUC that he is concerned about pain control would be to use a pain scoring sheet detailing the frequency of monitoring and any plans to increase administration of pain-relieving medications if indications of pain or discomfort are observed.

Wycoff has also not addressed the issue of appropriate controls for his study by consulting with a statistician. One might assume that un-elongated tibial tissue would be used as a control; in animals undergoing a single procedure, the unaffected leg would serve this purpose, allowing each dog to serve as its own control. It is not clear what the control would be in animals undergoing procedures on both hind limbs. A lack of appropriate controls could result in Wycoff needing to re-do his experiments, not only causing more pain and distress but also increasing the number of animals used on the protocol.

In addition, Wycoff needs to re-read the definition of a major operative procedure. Although his proposed procedures do not expose a body cavity, they do involve extensive tissue dissection or transection, which places them in the category of a major operative procedure3. These procedures must be justified adequately and scientifically in his protocol.

Were Wycoff able to adequately justify the procedures, he would still need to address the issue of the animals' welfare post-operatively. Stating that he will provide mobility carts does not assure that the animal's welfare is addressed. The dogs should be acclimated to the carts before the procedures to help identify which dogs are better surgical candidates than others. Dogs that do not acclimate, as determined by a veterinarian, should not be included in the study. An acclimation plan would perhaps give the IACUC more confidence in the investigator's research proposal. Wycoff also does not address how the dogs will be managed while they are sleeping (when most dogs prefer a lateral position) or how dogs would be prevented from attempting to jump up from a sleeping position.

We feel the IACUC acted appropriately in denying the amendment until Wycoff has adequately addressed issues of pain control, multiple operative procedures, appropriate study controls and other welfare issues.

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